On 6 April 2016, the Sunset Clause, which prohibits platform service providers from receiving cash rebates, came into effect. In order to ensure continuing compliance with the Platform Rules, we will no longer invoice or accept commission payments in respect of platform remuneration from Product Providers. We have notified our Product Partners to 'switch off' commission payments. The last trail commission payment we have paid out was for accruals for Q1 2016. Trail commission will no longer be paid. That said, if we receive further commission for accruals that relate to periods prior to 31 March 2016, we will pay these out as ad hoc payments.
To fulfil our regulatory obligations, we will continue to offer clients the option to convert holdings in bundled share classes to unbundled share classes. However, we will no longer collect and pass through any commission that relates to periods post 6 April 2016.
FUND HOLDINGS – UNIT CONVERSIONS
The rationale for processing a share class conversion rather than selling the retail share class and subsequently purchasing the equivalent RDR / clean share class, is that conversions are not considered a disposal for tax purposes, nor should they give rise to Stamp Duty Reserve Tax (SDRT).
In terms of conversion costs, we have negotiated the charge with Pershing Securities Limited, our Custodian, who will execute the conversion process. Pershing's charge is £10 per line of stock, per account. This charge includes a conversion of the entire holding from a retail share class to an RDR / clean share class, which is significantly less expensive than the alternative option of selling the retail share class and purchasing the equivalent RDR / clean share class. There is no margin to Raymond James on this charge. This fee will be debited from the applicable account ten business days following the conversion date. If there are insufficient funds to cover the cost, the fee will be charged to the branch / office.
The way the process will work is that all retail share classes will be converted to the corresponding RDR-compliant, clean share class unless the wealth manager specifically elects not to have his/her clients’ units converted.